Comment on FR Doc # 2026-09158

Rebuttal – Recordkeeping in a Single Medium While I appreciate that ATF is not mandating electronic records, requiring licensees to maintain all records in a single medium creates an unnecessary burden for businesses that have adopted a hybrid system. Our business currently maintains an electronic Acquisition & Disposition (A&D) record while continuing to use paper ATF Form 4473s. This approach provides the best of both systems. Electronic A&D records allow us to quickly respond to firearm trace requests, while paper Form 4473s provide a reliable backup and a deliberate review process. Requiring us to transition entirely to electronic Form 4473s would impose significant financial hardship. It would require purchasing additional point-of-sale software modules, customer-facing electronic signature hardware, and related technology, despite our current system functioning effectively and remaining compliant. Additionally, our paper process includes three separate reviews by three different individuals before each Form 4473 is filed. This quality-control process helps identify and correct errors before records are retained. An all-electronic process may create the perception that electronic validation alone is sufficient, potentially reducing the level of human review that has proven effective in ensuring accuracy. The proposed rule should continue to allow licensees the flexibility to maintain electronic A&D records while retaining paper Form 4473s. Hybrid recordkeeping has demonstrated that it can improve efficiency, maintain reliability, reduce costs, and support compliance without compromising ATF's regulatory objectives.